Since the REACH Regulation came into force in 2007, more than 23,000 chemicals have been registered with the European Chemicals Agency (ECHA). This means that extensive data on the toxicological properties, uses and safe handling of these chemicals are available and published on ECHA's website. The principle of "no data, no market" applies. This means that only registered substances (in quantities over one tonne per year) may be manufactured or imported in the EU. LANXESS has also registered over 900 chemical substances and has demonstrated in the registration dossiers that these substances are used safely.

REACH aims are achieved with a lot of effort

Submitting a registration dossier is not a one-off effort. Rather, registration dossiers have to be revised and updated on a regular basis, for example when the manufactured quantity of a chemical substance changes or when new information on the properties of the substance becomes available. In addition, the information requirements have often been increased in recent years and a lot of additional data, e.g. on substances in nanoform, had to be generated and submitted. Within the framework of the dossier and substance evaluation, authorities can request further information, e.g. studies to be conducted by the registrants of a substance. The study result must be submitted in the registration dossier. The implementation of the REACH requirements requires a very high expenditure of resources for the chemical industry. At LANXESS, a separate department ensures that the registration dossiers contain all the necessary information and are up to date. 
But this effort is also having an effect: no region in the world has such a wealth of data on chemical substances and their properties as the European Union. Several in-depth reviews of the REACH Regulation have shown that the REACH processes are working well to achieve a high level of protection for human health and the environment - even if there is still room for improvement in some areas, especially in terms of efficiency.

Planned revision of the REACH Regulation

In its Chemicals Strategy for Sustainability, the EU Commission announced that it would carry out a "targeted" revision of the REACH Regulation. These plans were specified in a recently published roadmap for the REACH revision. According to this roadmap, the European Commission wants to implement more stringent information requirements for registration dossiers, introduce a mixture assessment factor to take into account adverse effects caused by unintended mixtures, simplify communication in the supply chains, revise the provisions for dossier and substance evaluation, reform the authorisation and restriction processes, e. g. by exempting only so-called essential uses from restrictions, and reform the requirements for the enforcement of the REACH provisions. From LANXESS' point of view, the planned changes are by no means "targeted", but rather a far-reaching revision of the REACH Regulation. Such a strong tightening of the legal provisions of the REACH Regulation would place a heavy burden on the chemical and also the downstream processing industry and thus impair Europe as an important business location in international competition. 

Therefore, we call forward not only a targeted but also a proportionate revision of the REACH Regulation: Instead of further increasing the overall regulatory burden, the efficiency of REACH as a whole should be strengthened. This requires better interlinking of regulatory processes to create more transparency and legal certainty and ensuring harmonised enforcement of REACH provisions across the EU. 

For further information or if you have any questions, please contact Teresa Bernheim, Manager Chemicals Policy, at teresa.bernheim@lanxess.com.